Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
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Section 263 revision requires both inadequate enquiry and an unsustainable Assessing Officer view; where questionnaires, replies, office notes and correspondence show that issues were examined, revision cannot rest on mere disagreement. The notes further state that revision initiated through monitoring, pressure or dictates of higher departmental authorities is invalid where the assessments followed adequate enquiry, while other grounds may remain open. An interest-free advance to a wholly owned overseas subsidiary may constitute quasi-equity or shareholder funding, rather than a loan intended to earn interest, where it supports expansion and returns are expected through the assessee's business; a LIBOR-based adjustment is therefore unsustainable. Purchases supported by commercial records and made for business purposes may qualify as commercially expedient expenditure despite expiry of a distributorship agreement.
Section 263 revision requires both inadequate enquiry and an unsustainable Assessing Officer view; where questionnaires, replies, office notes and correspondence show that issues were examined, revision cannot rest on mere disagreement. The notes further state that revision initiated through monitoring, pressure or dictates of higher departmental authorities is invalid where the assessments followed adequate enquiry, while other grounds may remain open. An interest-free advance to a wholly owned overseas subsidiary may constitute quasi-equity or shareholder funding, rather than a loan intended to earn interest, where it supports expansion and returns are expected through the assessee's business; a LIBOR-based adjustment is therefore unsustainable. Purchases supported by commercial records and made for business purposes may qualify as commercially expedient expenditure despite expiry of a distributorship agreement.
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